AML / CTF Compliance

AML compliance for Australian real estate agencies

AUSTRAC obligations are serious. REA Hub gives real estate agencies the structure to run a defensible AML/CTF program — customer due diligence, risk assessments, SMR documentation, and beneficial ownership records per transaction.

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What REA Hub covers for AML/CTF compliance

Since 2018, Australian real estate agents have been required to comply with the AML/CTF Act as reporting entities to AUSTRAC. The obligations are detailed and the penalties for non-compliance are severe — up to $22 million for serious or repeated breaches. REA Hub gives your agency the structure to comply without the chaos.

AML/CTF risk assessments

Document your agency's AML/CTF risk assessment — customer types, transaction types, delivery channels, and geographic risk. Updated as required by AUSTRAC.

Customer due diligence (CDD)

Structured CDD checklists per transaction. Capture identity verification, beneficial ownership, source of funds, and enhanced CDD for higher-risk customers.

Beneficial ownership records

Record the beneficial owner for each purchase — the natural person who ultimately owns or controls the buyer — in a structured, auditable format.

SMR decision documentation

Log suspicious matter assessments and SMR submissions with timestamps and reasoning — so your decision-making process is defensible under AUSTRAC audit.

AML program documentation

Store your AML/CTF program document with version history, review dates, and compliance officer sign-off. Always current and accessible.

Employee AML training records

Track AML/CTF training completion per staff member. The AML/CTF Act requires ongoing employee awareness training as part of a compliant program.

Real estate AML compliance — frequently asked questions

Are Australian real estate agents required to comply with AML/CTF laws?

Yes. Under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), real estate agents who provide designated services — including buying or selling real property on behalf of a customer — are reporting entities with obligations to AUSTRAC. These include enrolling with AUSTRAC, implementing an AML/CTF program, conducting customer due diligence, and reporting suspicious matters.

What is customer due diligence (CDD) for real estate agents?

CDD requires real estate agents to identify and verify the identity of their customers before providing a designated service. For purchases above certain thresholds, agents must also identify the beneficial owner — the person who ultimately owns or controls the buyer. Enhanced due diligence applies to higher-risk transactions, including those involving foreign persons or politically exposed persons.

What must an AML/CTF program include for a real estate agency?

An AML/CTF program for a real estate agency must include: a risk assessment of the agency's exposure to money laundering and terrorism financing; customer due diligence procedures; an employee due diligence program; a designated AML/CTF compliance officer; ongoing transaction monitoring; and a suspicious matter reporting process. AUSTRAC can audit programs at any time.

What is a suspicious matter report (SMR)?

An SMR must be submitted to AUSTRAC when an agent suspects or has reasonable grounds to suspect that a transaction involves proceeds of crime, or is related to terrorism financing. SMRs must be submitted within 24 hours (terrorism financing) or 3 days (other suspicious matters). Failure to report is a serious offence.

How does REA Hub help real estate agencies meet AML/CTF obligations?

REA Hub provides structured templates for AML risk assessments, CDD checklists for each transaction, beneficial ownership records, and documentation of suspicious matter decisions. All records are timestamped, auditable, and accessible — so your AML program holds up under AUSTRAC scrutiny.

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